NR-1 in force: what leaders should observe and forward without diagnosing employees

The new wording of chapter 1.5 of Regulatory Standard No. 1 came into force on May 26, 2026. It explains that Occupational Risk Management must cover psychosocial risk factors related to work. The change does not transform managers into psychologists, doctors or clinical evaluators: the focus of management continues to be on identifying dangers present in the conditions and organization of work, assessing risks and implementing prevention measures.

For leadership, the rule of thumb can be summarized as follows:

The manager's role is to act on the work — not to attribute a diagnosis to the worker.

This means observing demands, processes, relationships, resources and concrete events; record facts objectively; make operational adjustments within the authority itself; and contact HR, Occupational Health and Safety or health professionals depending on the nature of the situation.

What came into force on May 26, 2026

MTE Ordinance No. 1,419, of August 27, 2024, expressly included work-related psychosocial risk factors in the chapter on Occupational Risk Management. Subsequently, MTE Ordinance No. 765, of May 15, 2025, extended the beginning of this new wording until May 25, 2026. The official NR-1 page records that the text came into force on May 26, 2026.

NR-1 determines that the organization:

• identify dangers and possible injuries;
• evaluate and classify risks;
• implement prevention measures;
• monitor risk control;
• consider working conditions under the terms of NR-17;
• promote worker participation and consultation;
• communicate the risks consolidated in the inventory and the measures foreseen in the action plan.

The Risk Management Program must contain, at a minimum, risk inventory and action plan. For each prevention measure, the standard requires a schedule, those responsible, monitoring and measurement of results. Presenting only formal documents, without consistency with real conditions, tends to be insufficient in an inspection.

Psychosocial risk is not synonymous with diagnosis

In the context of NR-1, psychosocial risk factors are hazards related to the design, organization and management of work. The assessment must verify which characteristics, demands and conditions of the activity can act as stressors — and not look for individual symptoms, measure personal sensations as if they were a diagnosis or conclude that a certain worker has a disorder.

Among the examples presented by the Ministry of Labor and Employment guide are:

• excess or insufficiency of demands;
• low clarity of role or function;
• lack of support at work;
• low control or little autonomy;
• inadequate change management;
• low perception of organizational justice;
• bad relationships in the workplace;
• difficult communication;
• remote or isolated work;
• harassment of any nature;
• exposure to violent or traumatic events.

These factors may be present without a known clinical diagnosis. Likewise, the existence of a diagnosis does not, in itself, prove that the cause lies in work. The GRO assesses occupational conditions; individual clinical assessment belongs to qualified health professionals.

What leadership can observe

The manager can observe facts such as:

• conflicting priorities received by the same team;
• volume of work incompatible with deadline, resources or available personnel;
• long working hours or recurring calls outside of working hours;
• activities without responsible person, decision criteria or clear instructions;
• lack of training for a task already assigned;
• relevant changes implemented without communication or support;
• isolation of a person from information necessary for work;
• frequent conflicts, humiliation, threats or aggressive behavior;
• recurrent impossibility of taking planned breaks;
• absence of replacement during holidays, absences or predictable peaks.

These are elements of the work that can be described, verified, and escalated. Phrases like “he is depressed,” “she has burnout,” or “this person is emotionally unstable” are clinical hypotheses or labels — not adequate risk management records.

Matrix of responsibilities: leadership, HR, OSH and health

NR-1 and NR-17 do not establish, in general, a single profession authorized to conduct the identification and assessment of psychosocial risks. The organization must define those responsible or a team with technical knowledge compatible with its activities and the complexity of the risks. Responsibility for the PGR remains with the organization.

The matrix below is a suggested governance model, not a mandatory legal distribution. It must be adapted to the size of the organization, the SESMT, the CIPA, the integrity channels, the formal attributions and the legal and privacy guidelines.

Legend: A = responsible for governance or decision; R = performs or leads; C = consulted; I = informed.

If the leadership itself is involved in the incident, the report should not depend on it to move forward. The flow must offer an alternative channel, such as HR, integrity, ombudsman, CIPA or formally designated person.

What each area should do

Leadership: observe, act and direct

Leadership is close to day-to-day execution and usually notices priority conflicts, process failures, load changes and communication difficulties first. Your role is:

1. interrupt or reduce the problem within your authority, when possible;
2. listen without clinically questioning;
3. record verifiable facts;
4. forward to the appropriate channel;
5. participate in prevention measures;
6. monitor whether the adjustment worked.

The manager does not need to wait for an annual survey, a leave of absence or a diagnosis to correct contradictory priorities, clarify responsibilities or review an evidently unbalanced distribution of tasks.

HR: people governance and institutional channels

HR can support policies, manager training, reporting channels, conflict management, disciplinary procedures, organizational changes and integration between areas. When there is an allegation of harassment, discrimination or other possible infraction, the investigation must follow an impartial procedure, with the participation of integrity or legal when applicable.

HR should not turn health information into performance comments, widely shared spreadsheets, or labels used in career decisions.

SST: technical assessment and integration into GRO

SST — or the technically designated team — must structure the hazard identification, choose appropriate methods, articulate the Preliminary Ergonomic Assessment, indicate when an Ergonomic Work Analysis is necessary and integrate the results into the inventory and action plan.

The MTE guide presents AEP as an initial approach and AET as an in-depth analysis in the situations foreseen in NR-17. Observation of the activity, dialogue with workers and analysis of concrete conditions are relevant components, including in small groups.

Health professionals: clinical assessment and care

Individual clinical assessment, diagnosis, treatment and medical decisions must remain with qualified professionals. The MTE clarifies that periodic medical examinations do not replace the identification of hazards and the assessment of working conditions required by NR-1.

NR-7 establishes that data from clinical and complementary examinations are recorded in individual medical records under medical responsibility. The Occupational Health Certificate informs, among other elements, the relevant occupational factors and the definition of fit or unfit; clinical data remain separate in the medical record.

Consolidated information or occupational health statistics can support prevention measures and be discussed with OSH and CIPA, preserving the separation in relation to individual records.

How to record an incident without diagnosing

A good record answers four questions:

• What happened?
• When and where did it happen?
• What labor conditions were involved?
• What direction or measure was adopted?

Examples of suitable records

The examples below are fictitious:

• "On August 3, 2026, the team received three demands classified as urgent, due the following day, without defining priority among them. The conflict was forwarded to the board for reprioritization."
• "The worker reported that he took on the shift without access to the updated procedure and without training in the new system. Access was regularized and the case was forwarded to the SST for analysis."
• "During the meeting, there were repeated interruptions, raised voices and offensive comments. The meeting was closed and the incident was forwarded to the integrity channel."
• "Over the past four weeks, six team members have worked after hours on three or more days a week to complete the same process. Demand, deadline and capacity review requested."

Inadequate records

• “Employee is depressed.”
• “He seems to have burnout.”
• “He is emotionally fragile.”
• “Can’t stand pressure.”
• “He has a psychological problem.”
• “You need to take medication.”
• “The problem is familiar.”
• “It has a difficult and unstable profile.”

These formulations mix opinion, personality judgment, clinical hypothesis and possibly unnecessary personal information.

Health data is classified by the General Data Protection Law as sensitive personal data. The LGPD requires a defined purpose, necessity — that is, limitation to the minimum necessary —, security, prevention and non-discrimination. The organization must define the legal hypothesis and applicable controls; This decision should not be improvised by the manager recording a meeting.

Seven-Step Routing Flow

1. Observe the work, don't try to interpret the personality

Describe demands, deadlines, autonomy, support, conflicts, resources, journeys, changes and concrete events.

2. Listen without demanding clinical revelations

The person may report impact, discomfort or difficulty without reporting diagnosis, treatment, medication or family history. Leadership can welcome and guide without turning the conversation into a medical interview.

3. Check what can be fixed immediately

Reprioritizing demands, clarifying roles, offering resources, reorganizing coverage, suspending an inappropriate interaction, or revising a deadline can reduce exposure before a broader analysis is completed.

4. Keep an objective record

Use date, context, activity, observed facts, people or groups involved when strictly necessary and adopted direction. Avoid adjectives, clinical conclusions and indiscriminate circulation.

5. Contact the correct person in charge

• HR: policies, conflicts, organizational change, reporting channels and possible infringement.
• SST or designated team: technical assessment, AEP, AET, inventory, classification and action plan.
• Occupational or care health: clinical assessment and individual care.
• Integrity or legal: formal investigation and analysis of legal risks.
• Privacy or data steward: definition of access, purpose, retention and sharing of personal information.

6. Integrate the case into the collective analysis when applicable

An individual occurrence may reveal a condition that affects others. The technical referral must investigate the work and the exposed group, without publishing or disseminating the worker's clinical history.

7. Define measure, responsible, deadline and indicator

The action does not end at forwarding. The plan needs to indicate what will be changed, who will execute it, when it will occur and how the organization will verify its effectiveness.

Why a climate survey doesn't solve everything

Questionnaires can be useful as one of the sources of information, but the MTE states that their isolated application does not characterize the management of psychosocial risks and does not replace the AEP, the inventory or the action plan. Its results need to be technically interpreted and related to the real conditions of the activity.

This also goes for wellness programs, lectures, meditation apps or therapeutic benefits. They can form a support strategy, but they are not a substitute for correcting overload, incompatible priorities, lack of autonomy, abusive management or resource deficiency.

Errors that increase the risk for the organization

• Train managers to “detect disturbances” instead of observing work.
• Use one-on-one meetings as an impromptu clinical assessment.
• Require diagnosis before considering an operational adjustment.
• Record health hypotheses in performance documents.
• Share personal stories in message groups or open spreadsheets.
• Administer only one questionnaire and consider the PGR completed.
• Transfer all responsibility to HR or the health plan.
• Create an inventory without measurements, responsible parties, deadlines and monitoring.
• Do not offer an alternative channel when the superior is part of the incident.
• Treat a report as proven guilt before a proper investigation.

The starting point for leaders

Leadership does not need to know a diagnostic classification to realize that five simultaneous priorities, lack of support, public humiliation or lack of clarity are harming the work.

Responsible routing begins with three moves:

1. describe the fact without labeling the person;
2. reduce the work factor when there is authority to do so;
3. call the competent area for evaluation and monitoring.

Save the responsibility matrix and use it to review the flows between leadership, HR, OSH, health, integrity and privacy. As a next step, also consult the “1:1 meeting is not a performance review” guide and the internal material on meeting records.